Canada v. Schafer, 2000 DTC 6542 (FCA) -- summary under Subsection 334(1)

The appellant had been found by the trial judge not to have received a notice of assessment. The Court found that the "sent" wording of s. 301(1.1) was clear and unambiguous, and that therefore there is not requirement that the notice be received in order to start the limitation running. The Court found that even if s. 301(1.1) had not applied to start the limitation period running from the date of mailing of the notice of assessment, s. 334(1) applied to deem the respondent to have received the notice of assessment on the date of mailing.